ML14079A138

2014/03/20 Indian Point Lr Hearing - Draft Telecon Summary for Call on February 20, 2014

ML14079A138
Person / Time
Site:	Indian Point
Issue date:	03/20/2014
From:	Office of Nuclear Reactor Regulation
To:	Division of License Renewal
References
Download: ML14079A138 (6)

Text

IPRenewal NPEmails From: Green, Kimberly Sent: Thursday, March 20, 2014 9:19 AM To: Waters, Roger M.

Cc: Uribe, Juan; IPRenewal NPEmails

Subject:

RE: Draft Telecon Summary for Call on February 20, 2014 Attachments: IP Draft RAI LR-ISG-2012-02 and LR-ISG-2013-01 Revised.docx

Roger, After I sent the draft summary, I realized that I should have reflected the change to wording for the RAI. The change has been made to the draft RAI, and the letter will reflect a response date of 180 days from the date of the letter. In addition, I will revise the call summary as suggested.

Attached is the revised draft RAI. The only change is to the second question under number 1 of the Issue. Ive removed the wording (IP2) and prior to the period of extended operation (IP3).

Please let me know if there are any other changes/clarifications needed to the draft RAI or the summary.

Kim From: Waters, Roger M. [1]

Sent: Thursday, March 20, 2014 8:57 AM To: Green, Kimberly

Subject:

RE: Draft Telecon Summary for Call on February 20, 2014

Kim, Would it be possible to add the following?:

The applicant requested some changes to the wording of the draft RAIs. The staff agreed to consider these requested changes and provide revised draft RAIs prior to issuance of the final version.

The applicant requested a 180-day response period for these RAIs. The staff agreed to this request.

Thanks, Roger From: Green, Kimberly [2]

Sent: Tuesday, March 18, 2014 11:29 AM To: Waters, Roger M.

Cc: Uribe, Juan; IPRenewal NPEmails

Subject:

Draft Telecon Summary for Call on February 20, 2014

Roger, Attached is the draft telecon summary for the call that was held on February 20, 2014. Please let me know if any changes or corrections are needed to the summary.

Ive copied Juan Uribe on this email. If Im out of the office, he will be able to answer your questions.

Thanks, 1

Kim 2

Hearing Identifier: IndianPointUnits2and3NonPublic_EX Email Number: 4503 Mail Envelope Properties (F5A4366DF596BF458646C9D433EA37D701682075C7FC)

Subject:

RE: Draft Telecon Summary for Call on February 20, 2014 Sent Date: 3/20/2014 9:18:52 AM Received Date: 3/20/2014 9:18:53 AM From: Green, Kimberly Created By: Kimberly.Green@nrc.gov Recipients:

"Uribe, Juan" <Juan.Uribe@nrc.gov>

Tracking Status: None "IPRenewal NPEmails" <IPRenewal.NPEmails@nrc.gov>

Tracking Status: None "Waters, Roger M." <rwater1@entergy.com>

Tracking Status: None Post Office: HQCLSTR01.nrc.gov Files Size Date & Time MESSAGE 1783 3/20/2014 9:18:53 AM IP Draft RAI LR-ISG-2012-02 and LR-ISG-2013-01 Revised.docx 28661 Options Priority: Standard Return Notification: No Reply Requested: No Sensitivity: Normal Expiration Date:

Recipients Received:

D-RAI 3.0.3-1

Background:

Recent industry operating experience (OE) and questions raised during the staffs review of several license renewal applications (LRAs) have resulted in the staff concluding that several aging management programs (AMP) and aging management review (AMR) items in the LRA may not or do not account for OE involving recurring internal corrosion, corrosion occurring under insulation, managing aging effects of fire water system components, and certain other issues. In order to provide updated guidance, the NRC staff has issued LR-ISG-2012-02, Aging Management of Internal Surfaces, Fire Water Systems, Atmospheric Storage Tanks, and Corrosion Under Insulation (ADAMS Accession No. ML13227A361).

Issue:

The staff noted that the updated guidance may not have been incorporated into the respective AMPs and AMR items.

Request:

Provide details on how the updated guidance of LR-ISG-2012-02 has been accounted for in your AMPs and AMR items, or, where the revised recommendations will not be incorporated, state an exception and the basis for the exception. If necessary, provide revisions to LRA Section 3 tables, Appendix A, and Appendix B.

D-RAI 3.0.3-2

Background:

The staff has noted several recent industry OE events related to loss of coating integrity of internal coatings. This has resulted in the staff concluding that several AMPs and AMR items in the LRA may not or do not account for this OE. The staff recently issued draft LR-ISG-2013-01, Aging Management of Loss of Coating Integrity for Internal Service Level III (augmented)

Coatings (ADAMS Accession No. ML13262A442).

Issue:

Loss of coating integrity for Service Level III (augmented) coatings Industry OE indicates that degraded coatings have resulted in unanticipated or accelerated corrosion of the base metal and degraded performance of downstream equipment (e.g.,

reduction in flow, drop in pressure, reduction in heat transfer) due to flow blockage. Based on these industry OE examples, the staff has questions related to how the aging effect, loss of coating integrity due to blistering, cracking, flaking, peeling, or physical damage (e.g., cavitation damage downstream of a control valve), would be managed for Service Level III (augmented) coatings.

ENCLOSURE

For purposes of this RAI, Service Level III (augmented) coatings include:

1. Those installed on the interior of in-scope piping, heat exchanges, and tanks which support functions identified under 10 CFR 54.4(a)(1) and (a)(2), and

2. coatings installed on the interior of in-scope piping, heat exchangers, and tanks whose failure could prevent satisfactory accomplishment of any of the functions identified under 10 CFR 54.4(a)(3).

The term coating includes inorganic (e.g., zinc-based) or organic (e.g., elastomeric or polymeric) coatings, linings (e.g., rubber, cementitious), and concrete surfacers (e.g.,

concrete-lined fire water system piping. The terms paint and linings should be considered as coatings.

The staff believes that to effectively manage loss of coating integrity due to blistering, cracking, flaking, peeling, or physical damage of Service Level III (augmented) coatings an aging management program should include:

1. Baseline visual inspections of coatings installed on the interior surfaces of in-scope components should be conducted as soon as practical.

2. Subsequent periodic inspections where the interval is based on the baseline inspection results should be performed. For example:

a. If no peeling, delamination, blisters, or rusting are observed, and any cracking and flaking has been found acceptable, subsequent inspections could be conducted after multiple refueling outage intervals (e.g., six years or more if the same coatings are in redundant trains).

b. If the inspection results do not meet the above; but, a coating specialist has determined that no remediation is required, subsequent inspections could be conducted every other refueling outage interval.

c. If coating degradation was observed that required repair or replacement, or for newly installed coatings, subsequent inspections should occur at least once during the next two refueling outage intervals to establish a performance trend on the coatings.

3. All accessible internal surfaces for tanks and heat exchangers should be inspected. A representative sample of internally coated piping components not less than 73 1-foot axial length circumferential segments of piping or 50 percent of the total length of each coating material and environment combination should be inspected.

4. Coatings specialists and inspectors should be qualified in accordance with an ASTM International standard endorsed in RG 1.54, Service Level I, II, and III Protective Coatings Applied to Nuclear Power Plants, including staff guidance associated with a particular standard.

5. Monitoring and trending should include pre-inspection reviews of previous inspection results.

6. The acceptance criteria should include that indications of peeling and delamination are not acceptable. Blistering can be evaluated by a coating specialist; however, physical testing should be conducted to ensure that the blister is completely surrounded by sound coating bonded to the surface.

Request:

If coatings have been installed on the internal surfaces of in-scope piping, piping components, heat exchangers, or tanks, state how loss of coating integrity due to blistering, cracking, flaking, peeling, or physical damage will be managed. Describe the following:

1. the inspection method

2. the parameters to be inspected

3. when baseline inspections will commence and finish, and the frequency of subsequent inspections

4. the extent of inspections and the basis for the extent of inspections

5. the training and qualification of individuals involved in coating inspections

6. how trending of coating degradation will be conducted

7. acceptance criteria

8. corrective actions for coatings that do not meet acceptance criteria, and

9. the program(s) that will be augmented to include the above activities If necessary, provide revisions to LRA Section 3 tables, Appendix A, and Appendix B.